Verhaltenskodex

Scope

The Code of Conduct is applicable to all Reynaers Aluminium employees worldwide, including temporary personnel, as well as to all Reynaers Aluminium suppliers and subcontractors.

All employees have the clear objective to strive to use good judgement and consideration in their daily work. A dedicated set of rules, specified in this document will assist them:

 

• Respect and fair treatment of our employees and business partners;
• No corruption or infringements of antitrust laws to guarantee the principle of fair competition and free market;
• Respect for natural resources and adherence to environmental laws to ensure sustainable economic business and avoid environmental risks;
• Respect of data protection, intellectual property and privacy laws;
• Compliance with all relevant laws, policies and regulations.

Reynaers Aluminium reserves the right to amend this Code of Conduct at any time and for any reason.

Respect and fair treatment

All employees are expected to work and behave respectfully towards colleagues, business contacts and others, from any foreign culture or background. In line with this, we do not accept any form of harassment, discrimination or other behaviour that colleagues or business partners may regard as offensive or degrading.

Reynaers Aluminium is committed to strive for diversity and an inclusive work culture, valuing all individuals, without any form of discrimination.  In that sense, Reynaers Aluminium provides equal employment opportunities and treats all employees fairly.

Fair competition and full commitment to antitrust laws

Reynaers Aluminium commits to the highest standards of fair conduct when dealing with employees, suppliers, customers and other business contacts. All Reynaers Aluminium employees are expected to respect free competition and comply with the international anti-bribery standards, as stated in the United Nations Global Compact, as well with local anti-corruption laws. They are forbidden from being involved in anticompetitive agreements with third parties and from seeking or accepting advantages for themselves (or for any close relations) that are improper. Reynaers Aluminium does not tolerate any kind of corruption, bribery or any type of unlawful granting of advantages. Any benefit promised or received with the intent to influence the decision making process, both to business partners as to public officials, is forbidden. The offering of gifts or other favours can only be given or granted, provided they comply with locally accepted good business practice and they are transparent and reasonable, both with respect to value and frequency, without expectation of any kind of return.

Reynaers Aluminium commits to disclose information regarding our business activities and performance, in accordance to applicable laws and regulations.  Reynaers Aluminium employees shall not misuse company information or company property for their personal or any third party benefit

Respect natural resources and avoid environmental risks

Reynaers Aluminium is firmly committed to designing sustainable solutions and puts great effort into researching and developing energy efficient systems with respect for natural resources. This means we comply with all applicable environmental laws, regulations and standards, but as well implement an effective environmental management system to identify and eliminate potential hazards to the environment. In this sense, Reynaers Aluminium commits to avoid the use of hazardous substances and substitute them with non-hazardous (preferred) or less hazardous alternatives.

To ensure safe handling, movement, storage, recycling, re-use and disposal, we identify, eliminate and manage substances that pose a hazard if released in the environment and comply with applicable labelling laws and regulation for recycling and disposal.  We endeavour to reduce or eliminate waste of all types, including water and energy, by implementing appropriate conservation measures during production and maintenance processes and by recycling, re-using or substituting materials.

Data protection, intellectual property and privacy laws

Protecting intellectual property rights, data protection and respecting privacy from Reynaers Aluminium, employees, suppliers and other business partners is the responsibility of all parties (whether as data controller or data processor). All information and intellectual property rights must be used legitimately and maintained with care and respect, while avoiding abuse and preventing damage. Unauthorized transfer of information is strictly prohibited.

Reynaers Aluminium concludes a dedicated Non-Disclosure Agreement (or similar contractual provisions) with all its suppliers.

Other compliance with laws and regulations

Reynaers Aluminium is committed to comply with all applicable laws and regulations, some of them mentioned explicitly below:

 

Labour and human rights

Support and act to the principles of the United Nations Global Compact, the UN Universal Declaration of Human Rights as well as the International Labour Organization Declaration on Fundamental Principles and Rights at Work, in accordance with national law and practice.  This specially applies to:

• Child labour:
  
  In no case shall the work or employment of persons ages under 15 be permitted as this prevents the minor from complying with compulsory schooling or training requirements and is harmful to their health or development.
• Forced labour:
  
  In any case the use of forced or compulsory labour is prohibited.
• Compensation and working hours:
  
  Employees must be paid in a timely manner and it must comply with the respective national laws and regulations regarding working hours, wages, benefits and vacation time.

Health and safety

Comply with applicable occupational health and safety laws and regulations and provide a safe and healthy working environment to prevent accidents and injury.

• Occupational injury and chemical exposure prevention:
  
  Eliminate physical and chemical hazards where possible and set in place procedures to manage, track, and report occupational injury and illness. In all cases, employees have to receive the appropriate personal protective equipment. Workers must have the right to refuse unsafe working conditions without fear of reprisal until management adequately addresses their concerns.
• Emergency prevention and preparation:-
  
  Anticipate, identify and assess emergency situations and minimize their impact by implementing emergency plans and response procedures.
• Ergonomics:
  
  Identify, evaluate, control and improve worker exposure to physically demanding tasks, including manual material handling, heavy lifting, prolonged standing, and highly repetitive or forceful assembly tasks.

Tax

Reynaers Aluminium demonstrates ethical tax behaviour and pays the proper amounts of taxes in the countries where value is created. We pursue a strong relationship with governments. Transparency and trust are embedded in our business principles and corporate culture, thus play an important role in the way we engage with fiscal authorities throughout the world. Reynaers Aluminium acts in accordance with all applicable (tax) laws and regulations at all times. We aim to comply with the spirit as well as the letter of the law. Any action related to planning our tax position must be consistent with the normal course of business and in line with our overall group strategy.

Applicability on suppliers and their subcontractors

We expect all our suppliers (including freelancers), business partners and their subcontractors, to fully respect and act according to the rules in this Code of Conduct, and cascade these requirements to their own supply chain.

Regarding the topic ‘Respect natural resources and avoid environmental risks’, suppliers shall regularly review the use of hazardous substances and substitute them with non-hazardous (preferred) or less hazardous alternatives.

If requested by Reynaers Aluminium, suppliers will complete a self-assessment questionnaire regarding the compliance with this Code of Conduct and the steps supplier has taken to ensure that the supplier and its subcontractors fully comply.

Suppliers will allow Reynaers Aluminium to audit compliance with this Code of Conduct by inspecting their facilities, reviewing records, policies and practices and interviewing personnel. Suppliers are expected to provide prompt access to their facilities, records, documentation and will ensure the necessary assistance by their personnel.

If Reynaers Aluminium identifies any non-compliance, suppliers must prepare, and permit Reynaers Aluminium to review and execute an improvement plan approved by Reynaers Aluminium to rectify matters.

Subject to any contractual terms, Reynaers Aluminium may terminate the supply relationship if a supplier fails to comply with this Code of Conduct. If appropriate, Reynaers Aluminium may report any breach of the Code of Conduct to the appropriate authorities.

No rights created

This Code of Conduct is a statement of certain fundamental Reynaers Aluminium principles, policies and procedures that govern Reynaers Aluminium‘s employees and representatives. It does not create any right for any customer, supplier, competitor, shareholder or any other person or entity.